Sterling International v. Sorensen Research and Development Trust

7/28/2019 Sterling International v. Sorensen Research and Development Trust

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Scott C. Moore (CA SB N 20318 1)E-mail: S M [email protected] RRISON & FOERSTER LLP555 W est Fifth St.Los Angeles, CA 90013-1024Telephone: (213) 892-5200Facsimile: (213) 892-5454Brian F. McM ahon (CA SBN 235373)Email: brian.mcmahoncojk.comJohn D. Denkenberger (pro hac application pending)Email: [email protected] W. A nable (pro hac application pending)Email: [email protected] OCONNOR JOHNSON KINDNESS PLLC1420 Fifth Avenue, Suite 2800Seattle, Washington 98101-2347Telephone: (206) 682-8100Facsimile: (206) 224-0779Counsel for PlaintiffSTERLING INTERNATIONAL, INC.

UNITED STATES DISTRICT COURT

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CONFORMCOPY

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CENTRAL DISTRICT OF CALIFORNIACaseNPh1 3 - 00938COM PLAINT FORr aDECLARATORYJUDGMENT OF NON-INFRINGEM ENT ANDINVALIDITYDefendant.

Plaintiff Sterling International, Inc. ("Sterling"), through its undersignedcounsel, files this Complaint for Declaratory Judgment against Defendant.

Sterling International, Inc.,Plaintiff,

V.

Sorensen Research and DevelopmentTrust,

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1orensen Research and Development Trust ("Sorensen") seeking declaratory2elief with respect to U.S. Patent No. 6,599,460 ("the 460 Patent" or "the patent3n suit," attached as Exhibit A hereto) and hereby alleges as follows:4

I. THE PARTIES1. Sterling is a corporation organized and existing under the laws of

the State of Washington, with its principal place of business at 3808 N. SullivanRd., Bldg 16, Spokane Valley, WA 99216.

2 . Upon information and belief, Sorensen is a trust with its principalplace of business at 7040 Avenida Encinas, Suite 104-277, Carlsbad, CA 92011.

II. JURISDICTION AND VENUE3. This is an action for declaratory relief regarding the 460 Patent.4 . This Court has jurisdiction over the subject matter jurisdiction of

this action pursuant to 28 U.S.C. 1331 and 1338(a), in that it involves claimsarising under the United States Patent Act, 35 U.S.C. 1 et seq.

5. This Court may declare the rights and other legal relations of theparties pursuant to 28 U.S.C. 2201 and 2202 because there is a case of actualcontroversy within the Courts jurisdiction.

6. This Court has personal jurisdiction over Sorensen because itconducts business in the State of California and within this District, it hasvoluntarily availed itself of the laws and regulations of California and thisDistrict and, under the circumstances, the assertion of personal jurisdiction overcomports with traditional notions of fair play and substantial justice.

7. Venue properly lies in this judicial district pursuant to28 U.S.C. 1391.

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1II. THE PRESENCE OF AN ACTUAL CONTROVERSY2.pon information and belief, Sorensen is the purported assignee3nd sole owner of the 460 Patent.4.n December 13, 2012, Sorensen, through its counsel, issued a5ease and desist letter to Sterling. A true and correct of the December 13, 2012,6etter is attached as Exhibit B and is incorporated herein by reference in its7ntirety. In its cease and desist letter, Sorensen asserted its belief that Sterling is8using technology claimed" in the 460 Patent. (Exhibit B, p. 1.)90. Sorensen further alleged that Sterling is making insect traps under

10he name "Rescue W-H-Y Insect Traps" that allegedly infringe Claim 1 of the1 1460 patent.121.pecifically, in its December 13, 2012, letter, Defendant asserted1 3he following:14From our experts examination and testing, we have15etermined that the structure of the above referenced16roducts meets the claim limitations of [the 460 Patent]."17Id.,p. 1.).18Further, our records indicate that Sterling International is19ot currently licensed under the 460 Patent." (Id.).20The following table lists at least one line of Sterling2 1nternational products that our inspection shows to be22anufactured by a process that is substantially likely to23nfringe the 460 Patent (hereinafter, Accused Products)."24Id.,p.3).25Sterling International must obtain a license and releaseP 1 0 1nder the 460 patent for the Accused Products it imported271 3

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1nto, manufactured, offered for sale and/or sold within the2nited States." (Id.).3We are providing this drawing as an example of the4ccused Products that illustrate our infringement analysis."5Id.,p.4).6Sterling Internationals unauthorized use of the 460 patented7echnology is further substantiated by the enclosed claim8hart associated with the attached drawing." (Id.).9PLEASE TAKE FURTHER NOTICE: This letter

10onstitutes a notice of patent infringement in violation of1 15 U.S.C. 271." (Id., emphasis in original).12Sterling International is ultimately responsible for the1 3nfringement of the 460 Patent in making, importing,14ffering for sale or selling its products and components."1 51d, p- 5).161Sterling International is liable as a direct infringer for those17roducts made by a process that infringe United States18atents, including the 460 Patent." (Id.).19As stated above, this notice of infringement is an affirmative20ommunication of a specific charge of infringement against21he Accused Products satisfying the actual notice22equirement for tolling damages." (Id., p. 7).23By contrast, failure to license its usage of the 460 patented24echnology can only lead to the risk and expense of litigation,25n award of damages, and attorneys fees." (Id.).2627 4

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12. No product made and sold by Sterling, including its Rescue W-H-Y2nsect Traps line of insect traps, infringe any valid, enforceable claim of the3460 Patent.43. In light of the correspondence received from Sorensen as detailed5bove, Sterling in good faith believes that Sorensen will file suit imminently6gainst Sterling alleging infringement of certain claims of the 460 patent. An7ctual controversy therefore exists between the parties with respect to the8nfringement, validity, and scope of the claims of the 460 Patent.9V. FIRST CLAM FOR RELIEF

10Declaration of Non-Infringement of the 460 Patent)1 14. Plaintiff Sterling hereby incorporates by reference the allegations12ontained in paragraphs 1 through 13 as though fully set forth herein.135 . Defendant Sorensen claims to be the owner of all legal rights, title1 4nd interest in the 460 Patent, including the right to enforce the 460 Patent.156. Sorensen asserts that Sterlings Rescue W-H-Y Insect Traps16nfringe certain claims of the 460 Patent.177. Sterlings Rescue W-H-Y Insect Traps do not infringe any valid and18nforceable claim of the 1 460 Patent.198. None of Sterlings products infringes any valid and enforceable2 0laim of the 460 Patent.219. Sterling has not, either literally or under the Doctrine of22quivalents, directly, indirectly, or contributorily infringed, or actively induced23nfringement of, any claim of the 460 Patent, nor has Sterling otherwise violated2 4orensens rights under such patent.250. Based on Sorensens assertions and conduct described above,2 6terling believes in good faith that Sorensen imminently will file suit against2 7terling alleging infringement of certain claims of the 460 Patent. Because

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1terling makes and sells the insect traps Sorensen claims to infringe the2460 Patent, there is an actual and justiciable controversy between Sterling and3orensen relating to the purported infringement of the 460 Patent.41. Accordingly, a judicial declaration of non-infringement of the5laims of the 460 Patent is necessary and appropriate pursuant to68 U.S.C. 2201 in order to resolve this controversy.7. SECOND CLAIM FOR RELIEF8Declaration of Invalidity of Claims of the 460 Patent)92. Plaintiff hereby incorporates by reference the allegations contained

1 0n paragraphs 1 through 21 as though fully set forth herein.

1 13. At least Claim 1 of the 460 Patent is invalid for failure to meet one12r more of the requirements of Title 35 of the United States Code, including13ithout limitation, 35 U.S.C. 102, 103, and/or 112. For example, at least14laim 1 of the 460 Patent is invalid as anticipated and/or obvious in light of15vailable and known prior art, including but not limited to at least U.S. Patents1 61os. 4,117,950 and 5,839,603. At least Claim 1 of the 460 Patent is invalid for1 7ther reasons as well, including but not limited to the fact that the language of18ertain claims, assessed in light of the patents specification and other intrinsic1 9nd extrinsic evidence, is insufficiently definite to determine the claims scope.2 04. As outlined above, an actual and justiciable controversy has arisen21etween Sterling and Defendant Sorensen.2 25. Accordingly, a judicial declaration of invalidity of one or more

23laims, and at least that of Claim 1, of the 460 Patent is necessary and2 4ppropriate pursuant to 28 U.S.C. 2201 in order to resolve this controversy.25I. PRAYER FOR RELIEF2 6HEREFORE, Plaintiff requests this Court to grant the following relief:2 76STJ L\356 6 PL COMPLAI NT ( 3) .DOC



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1.hat Defendant, its agents, servants, officers, directors, employees,2ttorneys, privies, representatives, successors, assigns, and parent and subsidiary3ntities, and any and all persons in act of concert or participation with any of4hem, be temporarily, preliminarily, and permanently enjoined from:5. Threatening to assert or asserting the 460 Patent against Sterling,6ts agents, employees, suppliers or customers;7. Alleging that Sterlings products infringe any claim of the8460 Patent;9. Alleging that certain claims of the 460 Patent are valid and/or

10nforceable;1 1.declaration that Sterling has not and does not infringe, under any121heory, any claim of the 460 Patent;13.declaration that claims of the 460 Patent are invalid;14.udgment that the Sterling is the prevailing party in this action and15n award for costs and attorney fees incurred in this action; and16.ny and all other relief that the Court deems proper.1718192021222324252627

Dated: February 8, 2013CHRISTENSEN OCONNORJOHNSON KINDNESS PLLC

Brian F. McMahonJohn D. DenkenbergerJames W. AnableMORRISON & FOERSTER LLPScott C. MooreAttorneys for Plaintiff SterlingInternational, Inc.

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EXHIBIT A



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(12) United States PatentBrown et al.(54) PREVENTION OF VOID-BASED-IRREGULARITY FORMATION IN THIN-

WALL, INJECTION-MOLDED PLASTICPRODUCT(75) Inventors: Paul Philip Brown, San Diego, CA

(US); Jens Ole Sorensen, GrandCayman (KY)

(73) Assignee: Sorensen Research and DevelpomentTrust, San Diego, CA (US)(*) Notice:ubject to any disclaimer, the term of this

patent is extended or adjusted under 35U.S.C. 154(b) by 282 days.

(21) AppI. No.: 09/608,923(22) Filed:ul. 3, 2000(51) mt. Cl.7 ................................................ B29C 45/00(52) U.S. CI. .................. 264/328.12; 249/144; 425/577;

220/671; 220/675(58) Field of Search .........................264/328.1, 328.12;

220/675, 671; 425/577; 249/142, 144(56)eferences CitedU.S. PATENT DOCUMENTS3,532,291 A * 10/1970ewman..............242/118.31

3,679,119 A 7/1972 Copping3,944,124 A 3/1976 Hexel4,117,950 A 10/1978llen........................220/7824,140,828 A 2/1979 Copping4,467,994 A 8/1984orensen4,519,557 A */1985ewman...................220/6754,622,002 A 11/1986 Bormuth4,657,141 A 4/1987 Sorensen4,743,420 A 5/1988 Dufl4,789,326 A 1211988orensen4,807,775 A 2/1989orensen4,844,405 A 7/1989orensen4,935,188 A 6/1990 Sorensen4,959,005 A 9/1990 Sorensen

l i i i 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 I NUS006599460B1(10) Patent No.:S 6,599,460 Bi(45) Date of Patent:ul. 29, 2003

4,960,557 A 10/1990 Sorensen5,008,064 A 4/1991orensen5,045,268 A 9/1991orensen5,145,630 A 9/1992 Schad5,149,482 A 9/1992 Sorensen5,262,112 A 11/1993orensen5,839,603 A *1/1998mith et al ................20/3805,858,286 A 1/1999rown et at.5,879,613 A 3/1999rown et at.6,003,720 A *2/1999orisnoto et al .......... 220/608

FOREIGN PATENT DOCUMENTSEP 0 362 648 A2 4/1990EP 0 599 009 Al 6/1994JP 53-21256 2/1978JP 54-22481 2/1979JP 54-148082 11/1979* cited by examinerPrimary ExaminerJill L. Heitbrink(74) Attorney, Agent, or FirmEdward W. Callan(57)BSTRACTDuring injection molding of a thin-wall plastic product, suchas a drink cup, the formation of void-based irregularities isprevented in a thin-wall portion of the product formedwithin a zone of a thin-wall cavity section that is locatedbetween adjoining flow chambers, in which zone the thick-ness of the thin-wall cavity section increases in the generaldirection of flow within the flow chambers adjoining suchzone. Such void-based irregularity formation is prevented bydimensioning the mold cavity so that the thickness increasesin such direction at less than a threshold rate. The flowchambers do not extend to a rim portion of the thin-wallcavity section; and the respective inscribed-sphere dimen-sions of the adjoining flow chambers within a terminal zoneof the thin-wall cavity section adjacent a rim portion of themold cavity are less than the respective inscribed-spheredimensions of upstream portions of the adjoining flowchambers.

34 Claims, 3 Drawing Sheets

0.0316 0.0066 0.0035.15 THICK71

28 7 161 2i254 0.85DlA FLOW CHAMBER27 . (00oc J - 23

EXHIBIT APage 8



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4

27 2654U.S. Patentul. 29, 2003heet 1 of 3S 6,599,460 Bi14nFIG.10.0316 0.0066 0.0.15 THICK280 21202726 254 0.85D!A FLOW CHAMBERCDIG .2 23EXHIBIT APage 9



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44 50

54

FIG.5

FIG.6A

If AA

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U.S. Patentul. 29, 2003heet 3 of 3S 6,599,460 Bi"AL-1b

% j. IJFIG.6B

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An-

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US 6,599,460 Bi

The present invention generally pertains to injectionmolding of thin-wall plastic products and is particularlydirected to preventing the formation of void-based irregu-larities in thin-wall portions of such products.

Some thin-wall portions of some plastic products areinjection molded by using a mold cavity that includes flowchambers for directing injected fluid plastic material intothin-wall cavity sections located between the flow chambersto thereby form the thin-wall portions of the product.

For some products, it is desired to increase the thicknessof the thin-cavity section in the general direction of flowwithin the flow chambers adjoining said zone. However,when such thickness is so increased, void-based irregulari-ties sometimes occur in a thin-wall portion of the productthat is formed by fluid plastic material directed into a zoneof the thin-wall cavity section that is located betweenopposed flow chambers adjoining such zone because theinjected fluid plastic material that is directed into such zonemay surround one or more gaseous voids within such zoneduring the formation of the product, as shown in FIG. 1.

FIG. 1 illustrates a sequential flow-front pattern ofdirected plastic material within a region of a thin-wall cavitysection 10 adjacent the downstream extremities of a pair ofopposed flow chambers 12. The sequential flow-front pat-tern was determined by injecting different quantities of fluidplastic material into the flow chambers 12 and recording theextent of the resultant flow of such material directed into thethin-wall cavity section for each injection. it is seen thatwithin a zone of the thin-wall cavity section 10 that islocated between the flow chambers 12 the injected fluidplastic material that is directed into the thin-wall cavitysection 10 surrounds a gaseous void 14 during the formationof the product. Consequently the thin-wall of the productincludes an irregularity in the portion thereof that is formedin the zone of the thin-wall cavity section 12 in which thevoid 14 was surrounded by the directed fluid plastic materialduring the formation of the product. Such an irregularitymay be manifested as a hole and/or a fragile and/or miscol-ored wall in such portion of the product. When the productis a container, such as a drink cup, a hole in the wall willenable fluid to leak from the container.

We have discovered that the formation of such void-basedirregularities in the thin-wall portion of the product can beprevented within the zone of the thin-wall cavity section thatis located between the flow chambers in which the thicknessof the thin-wall cavity section increases in the generaldirection of flow within the flow chambers adjoining saidzone by dimensioning the mold cavity so that said thicknessincreases in said direction at less than a threshold rate. Whensaid thickness increases in said direction at a rate that equalsor exceeds the threshold rate, such void-based irregularitiesusually occur. The threshold rate for a zone is determinedempirically for each product, as described below in relationto the detailed description of the preferred embodiments.

The present invention provides a mold for injection-molding a product that includes at least one thin wall,comprising: a plurality of mold parts, which when combineddefine a mold cavity for forming the product and at least one

2gate from which fluid plastic material may be injected intothe mold cavity; wherein the mold cavity includes at leastone thin-wall cavity section and at least two opposed flowchambers that adjoin opposite edges of the thin-wall cavity

5 section for directing injected fluid plastic material from exitpositions of the said at least two opposed flow chambers intocorresponding entrance positions of the thin-wall cavitysection to thereby form at least one thin-wall portion of theproduct; wherein the at least one thin-wall cavity section

10 includes at least one zone that is located between said at leasttwo opposed flow a chambers; wherein within the at leastone zone inscribed-sphere dimensions at each entranceposition are smaller than inscribed-sphere dimensions at thecorresponding exit position of the adjoining flow chamber;

is and wherein within the at least one zone the thickness of theat least one thin-wall cavity section increases in the generaldirection of flow within the flow chambers adjoining saidzone, with said increase being at less than a threshold rate tothereby prevent injected fluid plastic material so directed

20 into the at least one zone from at any time surrounding anygaseous void within the at least one zone. "Inscribed-spheredimensions" are those dimensions in which a sphere can befitted.The present invention also provides a method of injection-

25 molding a product that includes at least one thin wall,comprising the steps of:

(a) combining a plurality of mold parts to define a moldcavity for forming the product and at least one gatefrom which fluid plastic material may be injected into30 the mold cavity, wherein the mold cavity includes atleast one thin-wall cavity section and at least twoopposed flow chambers that adjoin opposite edges ofthe thin-wall cavity section for directing injected fluidplastic material from exit positions of the said at leasttwo opposed flow chambers into correspondingentrance positions of the at least one thin-wall cavitysection to thereby form at least one thin-wall portion ofthe product, wherein the at least one thin-wall cavitysection includes at least one zone that is located40 between said at least two opposed flow chambers, andwherein within the at least one zone inscribed-spheredimensions at each entrance position are smaller thaninscribed-sphere dimensions at the corresponding exitposition of the adjoining flow chamber; and

(b ) injecting fluid plastic material from the gate into themold cavity to form the product;

wherein step (a) comprises combining mold parts thatdefine a said mold cavity in which within said at least

so one zone of the at least one thin-wall cavity section thethickness of the at least one thin-wall cavity sectionincreases in the general direction of flow within theflow chambers adjoining said zone, with said increasebeing at less than a threshold rate to thereby prevent

55 injected fluid plastic material so directed into the atleast one zone from at any time surrounding anygaseous void within the at least one zone.

Additional features of the present invention are describedwith reference to the detailed description of the preferredembodiments.

BRIEF DESCRIPTION OF THE DRAWINGFIG. 1 illustrates a sequential flow-front pattern of

directed plastic material within a region of a thin-wall cavity65 section in which a void is surrounded by such material

during the formation of a thin-wall portion of a productwithin the thin-wall cavity section.

EXHIBIT APage 12

PREVENTION OF VOID-BASED-IRREGULARITY FORMATION IN THIN-WALL, INJECTION-MOLDED PLASTICPRODUCT

BACKGROUND AND SUMMARY OF THEINVENTION



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FIG. 2 shows exemplary dimensions of a preferredembodiment of a thin-wall cavity section defined by a moldaccording to the present invention. FIG. 2 is drawn approxi-mately to scale.

FIG. 3 illustrates a sequential flow-front pattern ofdirected plastic material within the thin-wall cavity sectionshown in FIG. 2.

FIG. 4 is a perspective view of a drink-cup productinjected molded in the mold of the present invention.

FIG. 4A is a perspective view of a portion of the productof FIG. 4 that is formed during an empirical determinationof whether the rate of increase of the thickness of a thin-wallcavity section is below the threshold rate at which void-based irregularity formation is consistently prevented.

FIG. 5 is a sectional view of a mold in which the moldparts define a cavity section for molding the drink-cupproduct shown in FIG. 4.

FIG. 6A is a sectional view illustrating the respectiveinscribed-sphere dimensions in one embodiment of the moldcavity at an entrance position of a thin-wall cavity sectionand a corresponding exit position of an adjoining flowchamber, as seen along lines 6-6 in FIG. 2.FIG. 613 is a sectional view illustrating the respectiveinscribed-sphere dimensions in another embodiment of themold cavity at an entrance position of a thin-wall cavitysection and a corresponding exit position of an adjoiningflow chamber, as seen approximately along lines 6-6 inFIG. 2.

FIG. 6C is a sectional view illustrating the respectiveinscribed-sphere dimensions in still another embodiment ofthe mold cavity at an entrance position of a thin-wall cavitysection and a corresponding exit position of an adjoiningflow chamber, as seen approximately along lines 6-6 inFIG. 2.

FIG. 7 is a sectional view illustrating the respectiveinscribed-sphere dimensions in an embodiment of the moldcavity at an entrance position of a thin-wall cavity sectionand a corresponding exit position of an adjoining flowchamber near the downstream extremity of the flowchamber, as seen along lines 7-7 in FIG. 2.

DETAILED DESCRIPTIONReferring to FIG. 2, a preferred embodiment of a mold

cavity defined by a mold according to the present inventionincludes a thin-wall cavity section 20 and a pair of opposingflow chambers 21 adjoining opposite sides of the cavitysection 20 for directing injected fluid plastic material fromexit positions of the two opposed flow chambers 21 intocorresponding entrance positions of the thin-wall cavitysection 20 to thereby form a thin-wall portion of an injectionmolded product. The pair of opposing flow chambers 21extend from a feeding flow chamber 22 that is coupled to agale 23 defined by the mold.

An exemplary preferred embodiment of a thin-wall cavitysection 20 for forming a thin-wall portion of an injectionmolded plastic product is dimensioned as shown in FIG. 2.The material used for this exemplary embodiment waspolypropylene. The thin-wall cavity section 20 includes aninitial zone 24, a first intermediate zone 25, a secondintermediate zone 26 and a terminal zone 27. The terminalzone 27 extends to a rim portion 28 of the mold cavity atwhich a rim of a thin-wall portion of a product is formed.The dividing line between the initial zone 24 and the firstintermediate zone 25 is 90.35 mm. from the gate 23. Thedividing line between the first intermediate zone 25 and a

4second intermediate zone 26 is 111.76 mm. from the gate 23.The dividing line between the second intermediate zone 26and the terminal zone 27 is 122.94 mm. from the gate 23.The initial zone 24, the first intermediate zone 25 and thesecond intermediate zone 26 are located completely betweenthe pair of opposing flow chambers 21. Neither of the pairof opposing flow chambers 21 extends to the rim portion 28,whereby a substantial portion of the terminal zone 27 is notlocated between the opposing pair of flow chambers 21. Theprevention of formation of void-based irregularities in theterminal zone 27 is enhanced by not extending either of thepair of opposing flow chambers 21 to the rim portion 28.

The formation of void-based irregularities in the terminalzone 27 beyond the downstream extremities of the flow

15 chambers 21 may not be a problem when they occur veryclose to a rim portion 28.In the initial zone 24, the thin-wall cavity section 20 has

a uniform thickness of 0.15 mm. In the first intermediatezone 25, the thickness of the at least one thin-wall cavity

20 section 20 increases in the general direction of flow withinthe flow chambers 21 adjoining the first intermediate zone25 at a rate of 0.0035. In the second intermediate zone 26,the thickness of the at least one thin-wall cavity section 20increases in the general direction of flow within the flow

25 chambers 21 adjoining the second intermediate zone 26 at arate of 0.0066. In the terminal zone 27, the thickness of theat least one thin-wall cavity section 20 increases in thegeneral direction of flow within the flow chambers 21closest to the terminal zone 27 at a rate of 0.0316. Each ofthe opposing flow chambers 21 adjoining the initial zone 24,the first intermediate zone 25 and the second intermediatezone 26 has a diameter of 0.85 mm. Approaching thedownstream extremities of the opposed flow chambers 21,the respective inscribed-sphere dimensions of the flowchambers 21 are less than the respective inscribed-spheredimensions of upstream portions of the adjoining flowchambers 21. Such decrease in the respective inscribed-sphere dimensions of the flow chamber 21 further enhancesprevention of formation of void-based irregularities in the

40 terminal zone 27.Referring to FIG. 3, which illustrates a sequential flow-

front pattern of directed plastic material within the thin-wallcavity section shown in FIG. 2, it is seen that the injectedfluid plastic material that is directed into the thin-wall cavity

45 section 20 does not at any time surround any gaseous voidwithin any zone of the thin-wall section 20 that is locatedbetween the pair of opposing flow chambers 21 (includingzones 24, 25, 26 and the portion of zone 27 that is locatedbetween the opposing flow chambers 21).

50drink cup 40, as shown in FIG. 4, having a plurality ofthin-wall portions 42 was injected molded by the method ofthe present invention in a mold 44 according to the presentinvention, as shown in FIG. 5. The mold 44 includes aplurality of mold parts 45, 46, which when combined define

55 a mold cavity 48 for forming the drink-cup 40 and a gate 50from which fluid plastic material is injected into the moldcavity 48. The mold cavity 48 includes a plurality ofthin-wall cavity sections 20, as shown in FIG. 2, and aplurality of adjoining opposed flow chambers 21 at opposite

60 edges of each thin-wall cavity section 20. The thin-wallportions 42 of the drink cup 40 are formed in the thin-wallcavity sections 20. The drink cup 40 also includes ridges 52,which are formed in the flow chambers 21 of the mold cavity48. The ridges 52 do not extend to a rim 54 of the cup 40.

65 Each thin-wall cavity section 20 of the mold cavity 48includes an initial zone 24, a first intermediate zone 25, asecond intermediate zone 26 and a terminal zone 27, which

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are located and dimensioned as described above with refer-ence to FIG. 2.

The threshold rate of increase in the thickness of thethin-wall cavity section 20 within each of the first interme-diate zone 25, the second intermediate zone 26 and theterminal zone 27 below which void-based irregularity for-mation between the adjoining flow chambers 21 is preventedwithin all such zones 25, 26, 27 was determined empiricallyby injection molding test strips generally corresponding toan individual common thin-wall portion 42 of the drink cup40, with different quantities of fluid plastic material beinginjected into a mold cavity, such as shown in FIG. 2, inwhich the rate of increase in the thickness is varied for eachsuch zone 25, 26, 27 separately, and observing the respectiverates of increase of the thickness within each zone 25, 26,27at which void-based irregularity formation is or is notprevented.

The dimensions of the mold cavity 48 were initiallyselected in accordance with such test-strip determinations.Partial test products 56, such as shown in FIG. 4A, were theninjected molded with different quantities of. fluid plasticmaterial being injected into the mold cavity 48 to determinewhether the respective rates of increase of the thicknesswithin each of the first intermediate zone 25, the secondintermediate zone 26 and the terminal zone 27 of thethin-wall cavity section 20 that were determined by observ-ing the test strips were such that void-based irregularityformation between the adjoining flow chambers 21 in eachof the zones 25, 26, 27 was consistently prevented. Whenobservation of the partial test products 56 reveals thatvoid-based irregularity formation is not consistentlyprevented, the rate of increase in the thickness is reduced inthe zone or zones in which void-based irregularity formationis not consistently prevented; and further test strips andpartial test products 56 are injection molded for furtherobservation.

FIGS. 6A, 613 and 6C illustrate the respective inscribed-sphere dimensions at an entrance position of a thin-wallcavity section and a corresponding exit position of anadjoining flow chamber in three alternative embodiments ofthe mold cavity 48.

In the mold cavity of FIG. 6A, the entrance position 60aof the thin-wall cavity section 20a is of approximatelyuniform thickness in a direction normal to the direction offlow within the adjoining flow chamber 21a; the cross-section of the flow chamber 21a is circular in the directionnormal to the direction of flow within the flow chamber 21a;and here is a sharp transition between the exit position 62aof the flow chamber 21a and the entrance position 60a of the 50thin-wall cavity Section 20a. Injected fluid plastic material isdirected from the exit position 62a of the flow chamber 21ainto the corresponding entrance position 60a of the thin-wallcavity section 20a; and the inscribed-sphere dimension 64aat the entrance position 60a is smaller than the inscribed-sphere dimension 66a at the corresponding exit position 62aof the adjoining flow chamber 21a.

In the mold cavity of FIG. 613, the entrance position 60bof the thin-wall cavity section 20b is of approximatelyuniform thickness in a direction normal to the direction of 60flow within the adjoining flow chamber 21b; the cross-section of the flow chamber 21b is oval in the directionnormal to the direction of flow within the flow chamber 21a;and there is a tapered transition between the exit position62b of the flow chamber 21b and the entrance position 60b 65of the thin-wall cavity section 20b. Injected fluid plasticmaterial is directed from the exit position 62b of the flow

FIG. 7 illustrates the respective inscribed-sphere dimen-sions at an entrance position 60a of the thin-wall cavitysection 20a and a corresponding exit position 62a of theadjoining flow chamber 21a near the downstream extremityof the flow chamber 21a in an embodiment of the moldcavity corresponding to that shown in FIG. 6A. The entranceposition 60a of the thin-wall cavity section 20a is ofapproximately uniform thickness in a direction normal to thedirection of flow within the adjoining flow chamber 21a; thecross-section of the flow chamber 21a, (which resides withinthe generally concave surface of the mold cavity 48) issemicircular in the direction normal to the direction of flowwithin the flow chamber 21a; the flow chamber 21a has asmaller inscribed-sphere dimension than in the upstreamportion of the flow chamber 21a shown in FIG. 6A; andthere is a sharp transition between the exit position 62a ofthe flow chamber 21a and the entrance position 60a of thethin-wall cavity section 20a. Injected fluid plastic material isdirected from the exit position 62a of the flow chamber 21ainto the corresponding entrance position 60a of the thin-wallcavity section 20a; and the inscribed-sphere dimension 64aat the entrance position 60a is smaller than the inscribed-sphere dimension 68a at the corresponding exit position 62aof the adjoining flow chamber 21a.

In additional alternative embodiments (not shown), (a) atleast one of the adjoining flow chambers does not extendfrom the gate either directly or via one or more connectedintervening flow chambers; (b) the direction of flow withinan elongated flow chamber is not necessarily lengthwise; (c)opposed flow chambers do not necessarily direct fluid plasticmaterial toward a common position between the opposedflow chambers; (d) flow chambers may be curved and/orshaped in any manner; (e) thin-wall cavity sections need notbe relatively fiat or conical; ( a thin-wall cavity sectionmay be interposed between at least one flow chamber andthe gate; and (g) meld chambers, such as described in U.S.Pat. No. 4,844,405, may be disposed within the thin cavityregion between the opposed adjoining flow chambers tofurther enhance prevention of formation of void-basedirregularities in those zones of the thin-wall section 20 thatare located between the pair of opposing flow chambers 21.

The advantages specifically stated herein do not neces-sarily apply to every conceivable embodiment of the presentinvention. Further, such stated advantages of the presentinvention are only examples and should not be construed asthe only advantages of the present invention.

While the above description contains many specificities,these should not he construed as limitations on the scope ofthe present invention, but rather as examples of the preferredembodiments described herein. Other variations are possible

EXHIBIT APage 14

20

25

30

35

chamber 21b into the corresponding entrance position 60b ofthe thin-wall cavity section 20b; and the inscribed-spheredimension 64b at the entrance position 60b is smaller thanthe inscribed-sphere dimension 66b at the corresponding

5 exit position 62b of the adjoining flow chamber 21b.In the mold cavity of FIG. 6C, the thickness of the

entrance position 60c of the thin-wall cavity section 20cdecreases in a direction away from and normal to thedirection of flow within the adjoining flow chamber 21c.

10 Injected fluid plastic material is directed from the exitposition 62c of the flow chamber 21c into the correspondingentrance position 60c of the thin-wall cavity section 20c; andthe inscribed-sphere dimension 64c at the entrance position60 c is smaller than the inscribed-sphere dimension 66c at the

15 corresponding exit position 62c of the adjoining flow cham-ber 21c.



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US 6,599,460 Bi7and the scope of the present invention should be determinednot by the embodiments described herein but rather by theclaims and their legal equivalents.We claim:

1. A method of injection-molding a product that includesat least one thin wall, comprising the steps of:(a ) combining a plurality of mold parts to define a moldcavity for forming the product and at least one gate

from which fluid plastic material may be injected intothe mold cavity, wherein the mold cavity includes atleast one thin-wall cavity section and at least twoopposed flow chambers that adjoin opposite edges ofthe thin-wall cavity section for directing injected fluidplastic material from exit positions of the said at leasttwo opposed flow chambers into correspondingentrance positions of the at least one thin-wall cavitysection to thereby form at least one thin-wall portion ofthe product, wherein the at least one thin-wall cavitysection includes at least one zone that is locatedbetween said at least two opposed flow chambers, andwherein within the at least one zone inscribed-spheredimensions at each entrance position are smaller thaninscribed-sphere dimensions at the corresponding exitposition of the adjoining flow chamber; and

(b) injecting fluid plastic material from the gate into themold cavity to form the product;

wherein step (a) comprises combining mold parts thatdefine a said mold cavity in which within said at leastone zone of the at least one thin-wall cavity section thethickness of the at least one thin-wall cavity sectionincreases in the general direction of flow within theflow chambers adjoining said zone, with said increasebeing at less than a threshold rate to thereby preventinjected fluid plastic material so directed into the atleast one zone from at any time surrounding anygaseous void within the at least one zone.2. A method according to claim 1, wherein the mold cavity

includes a plurality of said thin-wall cavity sections and aplurality of said adjoining at least two opposed flow cham-bers at opposite edges of each thin-wall cavity section; and

wherein each thin-wall cavity section includes at least onesaid zone located between the adjoining at least twoopposed flow chambers, in which inscribed-spheredimensions at each entrance position are smaller thaninscribed-sphere dimensions at the corresponding exitposition of the adjoining flow chamber; and in whichthe thickness of the thin-wall cavity section increases inthe direction of flow within the adjoining flow cham-bers at less than said threshold rate.3. A method according to claim 2, wherein the mold cavity

defines a hollow product.4. A method according to claim 3, wherein the mold cavity

defines a drink cup.5. A method according to claim 2, wherein each at least

one thin-wall cavity section extends to a rim portion of themold cavity in which a rim of the product is formed, andwherein none of at least two opposed flow chambers

adjoining the at least one thin-wall cavity Sectionextend to the rim portion.

6. A method according to claim 5, wherein within aterminal zone of the at least one thin-wall cavity sectionadjacent the rim portion of the mold cavity, the respectiveinscribed-sphere dimension of the adjoining flow chambersare less than the respective inscribed-sphere dimension ofupstream portions of the adjoining flow chambers.7. A method according to claim 2, wherein within aterminal zone of the at least one thin-wall cavity section

adjacent a rim portion of the mold cavity in which a rim ofthe product is formed, the respective inscribed-spheredimension of the adjoining flow chambers are less than therespective inscribed-sphere dimension of upstream portionsof the adjoining flow chambers.8. A method according to claim 1, wherein within aterminal zone of the at least one thin-wall cavity Sectionadjacent a rim portion of the mold cavity in which a rim ofthe product is formed, the respective inscribed-spheredimension of the adjoining flow chambers are less than therespective inscribed-sphere dimension of upstream portionsof the adjoining flow chambers.9. A method according to claim 1, wherein each at leastone thin-wall cavity section extends to a rim portion of themold cavity in which a rim of the product is formed, and

wherein none of at least two opposed flow chambersadjoining the at least one thin-wall cavity sectionextend to the rim portion.10. A method according to claim 9, wherein within aterminal zone of the at least one thin-wall cavity section20 adjacent the rim portion of the mold cavity, the respective

inscribed-sphere dimension of the adjoining flow chambersare less than the respective inscribed-sphere dimension ofupstream portions of the adjoining flow chambers.11. A method according to claim 9, wherein within a

25 terminal zone of the at least one thin-wall cavity Sectionadjacent the rim portion of the mold cavity, the thickness ofthe at least one thin-wall cavity section increases in thedirection of flow within the closest portions of the adjoiningflow chambers at a rate greater than the rate of increase

30 within the at least one zone of the at least one thin-wallcavity section.12. A method according to claim U, wherein a portion ofthe terminal zone is located between the adjoining at leasttwo opposed flow chambers.13. A method according to claim 11, wherein within anintermediate zone of the at least one thin-wall cavity sectionthat is located between the adjoining at least two opposedflow chambers and between the at least one zone and theterminal zone, the thickness of the thin-wall cavity section

40 increases in the direction of flow within the adjoining at leasttwo opposed flow chambers at a rate less than the thresholdrate, greater than the rate of increase within the at least onezone and less than the rate of increase within the terminalzone.

s4. A method according to claim 1, wherein within aninitial zone of the thin-wall section between the adjoining atleast two opposed flow chambers and upstream from the atleast one zone, the thickness of the thin-wall section does notchange in the direction of flow within the adjoining at least

50 two opposed flow chambers.15. A method according to claim 1, wherein the flowchambers are elongated in the direction in which injectedplastic material is directed within the flow chambers.16. A method according to claim 1, wherein at each

55 entrance position, the thin-wall cavity section is of uniformthickness in a direction normal to the general direction offlow within the adjoining flow chamber.17. A method according to claim 1, wherein the thicknessof each entrance position of the thin-wall cavity section

so decreases in a direction away from and normal to the generaldirection of flow within the adjoining flow chamber.18. A mold for injection-molding a product that includesat least one thin wall, comprising:

a plurality of mold parts, which when combined define a65 mold cavity for forming the product and at least one

gate from which fluid plastic material may be injectedinto the mold cavity;

EXHIBIT APage 15



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US 6,599,460 Bi90wherein the mold cavity includes at least one thin-wallcavity section and at least two opposed flow chambersthat adjoin opposite edges of the thin-wall cavity sec-

tion for directing injected fluid plastic material fromexit positions of the said at least two opposed flowchambers into corresponding entrance positions of thethin-wall cavity Section to thereby form at least onethin-wall portion of the product;

wherein the at least one thin-wall cavity section includesat least one zone that is located between said at leasttwo opposed flow chambers;

wherein within the at least one zone inscribed-spheredimensions at each entrance position are smaller thaninscribed-sphere dimensions at the corresponding exitposition of the adjoining flow chamber; and

wherein within the at least one zone the thickness of theat least one thin-wall cavity section increases in thegeneral direction of flow within the flow chambersadjoining said zone, with said increase being at lessthan a threshold rate to thereby prevent injected fluidplastic material so directed into the at least one zonefrom at any time surrounding any gaseous void withinthe at least one zone.19. A mold according to claim 1, wherein the mold cavity

includes a plurality of said thin-wall cavity sections and aplurality of said adjoining at least two opposed flow cham-bers at opposite edges of each thin-wall cavity section; and

wherein each thin-wall cavity section includes at least onesaid zone located between the adjoining at least twoopposed flow chambers, in which inscribed-spheredimensions at each entrance position are smaller thaninscribed-sphere dimensions at the corresponding exitposition of the adjoining flow chamber; and in whichthe thickness of the thin-wall cavity section increases inthe direction of flow within the adjoining flow cham-bers at less than said threshold rate.20. A mold according to claim 19, wherein the mold

cavity defines a hollow product.21. A mold according to claim 20, wherein the moldcavity defines a drink cup.22. A mold according to claim 19, wherein each at least

one thin-wall cavity section extends to a rim portion of themold cavity in which a rim of the product is formed, and

wherein none of at least two opposed flow chambersadjoining the at least one thin-wall cavity sectionextend to the rim portion.23. A mold according to claim 22, wherein within a

terminal zone of the at least one thin-wall cavity sectionadjacent the rim portion of the mold cavity, the respectiveinscribed-sphere dimension of the adjoining flow chambersare less than the respective inscribed-sphere dimension ofupstream portions of the adjoining flow chambers.24. A mold according to claim 19, wherein within aterminal zone of the at least one thin-wall cavity Sectionadjacent a rim portion of the mold cavity in which a rim ofthe product is formed, the respective inscribed-spheredimension of the adjoining flow chambers are less than therespective inscribed-sphere dimension of upstream portionsof the adjoining flow chambers.

25. A mold according to claim 18, wherein within aterminal zone of the at least one thin-wall cavity sectionadjacent a rim portion of the mold cavity in which a rim ofthe product is formed, the respective inscribed-spheredimension of the adjoining flow chambers are less than therespective inscribed-sphere dimension of upstream portionsof the adjoining flow chambers.26. A mold according to claim 18, wherein each at leastone thin-wall cavity section extends to a rim portion of thetO mold cavity in which a rim of the product is formed, and

wherein none of at least two opposed flow chambersadjoining the at least one thin-wall cavity sectionextend to the rim portion.

27. A mold according to claim 26, wherein within aterminal zone of the at least one thin-wall cavity sectionadjacent the rim portion of the mold cavity, the respectiveinscribed-sphere dimension of the adjoining flow chambersare less than the respective inscribed-sphere dimension of

20 upstream portions of the adjoining flow chambers.28. A mold according to claim 26, wherein within aterminal zone of the at least one thin-wall cavity sectionadjacent the rim portion of the mold cavity, the thickness ofthe at least one thin-wall cavity section increases in the

25 direction of flow within the closest portions of the adjoiningflow chambers at a rate greater than the rate of increasewithin the at least one zone of the at least one thin-wallcavity section.29. A mold, according to claim 28, wherein a portion of

30 the terminal zone is located between the adjoining at leasttwo opposed flow chambers.30. A mold according to claim 28, wherein within anintermediate zone of the at least one thin-wall cavity sectionthat is located between the adjoining at least two opposed

35 flow chambers and between the at least one zone and theterminal zone, the thickness of the thin-wall cavity sectionincreases in the direction of flow within the adjoining at leasttwo opposed flow chambers at a rate less than the thresholdrate, greater than the rate of increase within the at least one

to zone and less than the rate of increase within the terminalzone.31. A mold according to claim 18, wherein within aninitial zone of the thin-wall section between the adjoining atleast two opposed flow chambers and upstream from the at

45 least one zone, the thickness of the thin-wall section does notchange in the direction of flow within the adjoining at leasttwo opposed flow chambers.32. A mold according to claim 18, wherein the flowchambers are elongated in the direction in which injected

50 plastic material is directed within the flow chambers.33. A mold according to claim 18, wherein at eachentrance position, the thin-wall cavity section is of uniformthickness in a direction normal to the general direction offlow within the adjoining flow-chamber.

554. A mold according to claim 18, wherein the thicknessof each entrance position of the thin-wall cavity sectiondecreases in a direction away from and normal to the generaldirection of flow within the adjoining flow chamber.

EXHIBIT APage 16



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EXHIBIT B



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SORENSEN RESEARCH & DEVELOPMENT7040 AVENIDA ENCINAS, SUITE 104-277

CARLSBAD, CA 92011(858) 413-6062

Chris Kuczynski, Esq.Registered Patent [email protected]

December 13, 2012BY FEDEXRodney SchneidmillerPresidentSterling International, Inc.3808 N. Sullivan RoadBldg. # 16Spokane, WA 99216T : (509) 926-6766

CONFIDENTIAL OFFER OF COMPR OM ISESubject T o Federal Rules Of Evidence 408

RE:terling International, Inc.s (hereinafter "Sterling International") apparentunauthorized usage of the technology claimed in United States Patent No.6,599,460; Rescue W-H-Y Insect Trap, Our Case No. 7279, P757Dear Mr. Schneidmiller:We have recently examined several of Sterling Internationals products. From ourexperts examination and testing, we have determined that the structure of the abovereferenced products meets the claim limitations of United States Patent Number6,599,460 ("the 460 patent"). Further, our records indicate that Sterling International isnot currently licensed under the 460 patent.Further, for your information, Sorensen R&D also holds and controls the

following foreign counterparts of the 460 patent: Japanese Patent No. 4,717,273 andEuropean Patent No. 1174238. European Patent No. 1174238 has been designated in thefollowing contracting states: Germany, France, Italy, and the United Kingdom.Sorensen Research & Development ("Sorensen R&D"), is the owner of the 460patent entitled "PREVENTION OF VOID-BASED-IRREGULARITY FORMATION IN

EXHIBIT BPage 17



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Rodney SchneidmillerDecem ber 13, 2012Page 2 of 9

THIN-WALL, INJECTION-MOLDED PLASTIC PRODUCT," filed on July 3, 2000,Sorensen R&D is a leader in the field of plastic manufacturing technology. Its patents,both U.S. and foreign, are at the forefront of advances in manufacturing and disclosevaluable knowledge to the manufacturing industry in the form of significantimprovements to the processes used for manufacturing products. Sorensen R&D licensesthis valuable technology to various industries and promotes cutting-edge research anddevelopment efforts thereby fostering progress and the discovery of scientificadvancements in injection molding. Sorensen R&Ds patents teach innovative and cost-effective manufacturing process solutions that provide licensees with a competitiveadvantage Its patents further provide companies with limited capital, or limitedaccessibility to highly skilled scientists, access to advancements in research anddevelopment that would otherwise be unattainable.

Specifically, the 460 patent provides an elegant solution for injection molding ofplastic products with flow chambers and particularly for preventing the formation ofvoid-based irregularities in thin-wall portions of such products.

In 1962, Jens Ole Sorensen, a young mathematician, desiring to manufacture hisgeometric toy invention, founded 0 S Plastics In 1963, the company expanded toinclude production of flower pots, a product, which Sorensen sought to improve byminimizing the amount of raw material required per flower-pot, through an overallreduction in wall thickness. Sorensens thinner flower-pots became wildly successful,with O.S. Plastics growing to become the worlds largest manufacturer of flower-pots by1968, manufacturing an amount pots per year that if lined up side by side would span alength equal to the distance to the moon and back.

Spurred by success and market demands Sorensen dreamed of further minimizingthe amount of raw materials used per flower-pot. For seven years he worked to find away to use relatively less material near the base of the flower pot without sacrificingbreaking strength and while maintaining resistance to deformation, a feat nomanufacturer had yet been able to accomplish. Attempts at the time by the industry tomanufacture flower-pots with walls having thickness tapered to allow relatively lessmaterial near the bottom of the flower-pot resulted in difficulty of fully filling the moldand also caused an unacceptable warpage of the product.

At the time, the injection-molding industry had also experimented with the use offlow-ribs to lend strength to the walls of injection-molded products and to improve theflow of the injected plastic away from the gate to the distal ends of these products.Sorensen attempted to combine the flow-rib technology and the tapering of the wallthickness of his flower-pots to allow relatively less material to be used near the base. Thiscombined technique eliminated both the warpage problem and the mold filling problem,but at the expense of causing the formation of void-based irregularities in the productoccurring between the flow-ribs. These void-based irregularities caused weakness, colorchanges, and holes at their sites in the product walls.

EXHIBIT BPage 18



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SORENSEN RESEARCH & DEVELOPMENT7040 AVENIDA ENC INAS, SUITE 104-277CAfLSBAD, CA 92011(858) 413-6062

Chris Kuczynski, Esq.Registered Patent [email protected]

December 13, 2012B Y F E D E XRodney SchneidmillerPresidentSterling International, Inc.3808 N. Sullivan RoadBldg. ,# 16Spokane, WA 99216T : (509) 926-6766

CONFIDENTIAL OFFER OF COMPROMISESubject To Federal Rules Of Evidence 408

RE:terling International, Inc.s (hereinafter "Sterling International") apparentunauthorized usage of the technology claimed in United States Patent No.6,599,460; Rescue W-H-Y Insect Trap, Our Case No. 7279, P757Dear Mr. Schneidmiller:We have recently examined several of Sterling Internationals products. From ourexperts examination and testing, we have determined that the structure of the abovereferenced products meets the claim limitations of United States Patent Number6,599,460 ("the 460 patent"). Further, our records indicate that Sterling International isnot currently licensed under the 460 patent.

Further, for your information, Sorensen R&D also holds and controls thefollowing foreign counterparts of the 460 patent: Japanese Patent No. 4,717,273 andEuropean Patent No. 1174238. European Patent No. 1174238 has been designated in thefollowing contracting states: Germany, France, Italy, and the United Kingdom.

Sorensen Research & Development ("Sorensen R&D"), is the owner of -the 460patent entitled "PREVENTION OF VOID-BASED-IRREGULARITY FORMATION IN

EXHIBIT BPage 17



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Rodney ScFm eidmillerDecember 13, 2012Page 2 of 9

THIN-WALL, INJECTION-MOLDED PLASTIC PRODUCT," filed on July 3, 2000.Sorensen R&D is a leader in the field of plastic manufacturing technology. Its patents,both U.S. and foreign, are at the forefront of advances in manufacturing and disclosevaluable knowledge to the manufacturing industry in the form of significantimprovements to the processes used for manufacturing products. Sorensen R&D licensesthis valuable technology to various industries and promotes cutting-edge research anddevelopment efforts thereby fostering progress and the discovery of scientificadvancements in injection molding. Sorensen R&Ds patents teach innovative and cost-effective manufacturing process solutions that provide licensees with a competitiveadvantage Its patents further provide companies with limited capital, or limitedaccessibility to highly skilled scientists, access to advancements in research anddevelopment that would otherwise be unattainable.

Specifically, the 460 patent provides an elegant solution for injection molding ofplastic products with flow chambers and particularly for preventing the formation ofvoid-based irregularities in thin-wall portions of such products.

In 1962, Jens Ole Sorensen, a young mathematician, desiring to manufacture hisgeometric toy invention, founded 0.S. Plastics In 1963, the company expanded toInclude production of flower pots, a product, which Sorensen sought to improve byminimizing the amount of raw material required per flower-pot, through an overallreduction in wall thickness Sorensens thinner flower-pots became wildly successful,with 0 .S. Plastics growing to become the worlds largest manufacturer of flower-pots by1968, manufacturing an amount pots per year that if lined up side by side would span alength equal to the distance to the moon and back.

Spurred by success and market demands Sorensen dreamed of further minimizingthe amount of raw materials used per flower-pot. For seven years he worked to find away to use relatively less material near the base of the flower pot without sacrificingbreaking strength and while maintaining resistance to deformation, a feat nomanufacturer had yet been able to accomplish. Attempts at the time by the industry tomanufacture flower-pots with walls having thickness tapered to allow relatively lessmaterial near the bottom of the flower-pot resulted in difficulty of fully filling the moldand also caused an unacceptable warpage of the product.

At the time, the injection-molding industry had also experimented with the use offlow-ribs to lend strength to the walls of injection-molded products and to improve theflow of the injected plastic away from the gate to the distal ends of these products.Sorensen attempted to combine the flow-rib technology and the tapering of the wallthickness of his flower-pots to allow relatively less material to be used near the base. Thiscombined technique eliminated both the warpage problem and the mold filling problem,but at the expense of causing the formation of void-based irregularities in the productoccurring between the flow-ribs. These void-based irregularities caused weakness, colorchanges, and holes at their sites in the product walls.

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Rodney SchneidmillerDecember 13, 2012Page 7 of 9

As stated above, this notice of infringement is an affirmative communication of aspecific charge of infringement against the Accused Products satisfying the actual noticerequirement for tolling damages.

Sterling International must recognize that licensing the 460 patented technologywill allow it to continue to enjoy all the benefits and competitive advantages offered bythis useful patent. By contrast, failure to license its usage of the 460 patentedtechnology can only lead to the risk and expense of litigation, an award of damages, andattorneys fees.

There are scores of businesses that have licensed their usage of Sorensen R&Dspatented technology. Some of those businesses include Helen Of Troy, Microsoft,Hewlett-Packard Company, 3M Company, Adidas-Salomon, Atomic Ski, Bosch, BMWAG, Chicony Electronics, DamilerChrysler AG, Fluke, Head USA, Mercedes-Benz,Dremel, Garmin International, Irwin Tools, Milwaukee Electric (Milwaukee Tools),Nordica, Rubbermaid, Salomon, Skil, Strait-Line, Technica, The Stanley Works (StanleyTools), and W Jh_AJlyxL Sorensen R&D is committed to protecting the value to itslicensees by stopping mfiingement wherever it is found To protect Sorensen R&Dsintellectual property nghts, we cannot allow Sterling Internationals unlicensed usage tocontinue.

Courts have routinely found that the penalties for patent infringement can be highrelative to the economic benefit that the infringer might have realized from use of thetechnology. In Sneilman v. Ricoh Co, 862 F.2d 283 (Fed. Cir. 1988), cert. denied, 109S.Ct. 3199 (1989), the Federal Circuit upheld :a jury award equal to more than four timesthe infringers total sales revenue. In TVM Manufacturing Co. v. Dura Corp., 789 F.2d895 (Fed. Cir. 1986), cert. denied, 479 U.S. 852 (1986) the Federal Circuit approved a30% royalty granted by the trial court. The Federal Circuit in Blo-Rad La boratories, Inc.v . Nicolet Instrument Corp., 739 F.2d 604 (Fed. Cir.), cert. denied, 469 U .S. 1038 (1984)affirmed a royalty rate equal to one-third of the sales price of the infringing product. TheFederal Circuit in Deere & Co. v. International Harvester Co., 710 F.2d 1551 (Fed. Cir.1983) approved a 15 % royalty, despite the fact that some licenses were granted as low as1% .

In Weinar v. Roilform, Inc., 744 F.2d 79 7 (Fed. Cir. 1984), cert. denied, 470 U.S.1084 (1985), the Federal Circuit upheld an award of-three cents per infringing product,which resulted in a damage award exceeding the gross sales figure for the infringingdevice. The Court in DNIC Brokerage Co. v. Morrison and Dempsey Communications,Inc., 14 USPQ.2c1 1043 (C.D. Cal. 1989) awarded a royalty equal to 22% of theinfringers sales, stating that "the [p]laintiff is at least entitled to a royalty that prohibitsdefendants from profiting from their infringement by retaining the difference between areasonable royalty and their net profit." Finally, the Federal Circuit in Stickle v.Heublein, 716 F.2d 1550 (Fed. Cir. 1983) observed that "the trial court may award anamount of damages greater than a reasonable royalty... [because] the infringer would have

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Rodney ScimeidmillerDecember 13, 2012Page 8 of 9

nothing to lose, and everything to gain if he could count on paying only the normal,routine royalty non-infringers might have paid." This type of increase over an ordinary"reasonable royalty" is sometimes referred to by the Federal Circuit as a "reasonableroyaltyfbr an infringer."

The Federal Circuit has repeatedly stated that: "Intent is not an element ofinfringement. See, e.g., Kewanee Oil Co. v. Bicron Corp., 416 U.S. 470, 478, 94 S.Ct.1879, 1884, 40 L.Ed.2d 315 (1974). A patent owner may exclude others from practicingthe claimed invention, regardless of whether infringers even know of the patent" HiltonDavis Chem. Co. v. Warner-Jenldnson Co., 62 F3d 1512, 1519 (Fed. Cir. 1995),overruled on other grounds, 520 US 17 (1997).

This question [of infringement] is one irrespective of motive. The defendant mayhave infringed without intending, or even knowing it, but he is not, on thataccount, the less an infringer. His motives and knowledge may affect the questionof damages, to swell or reduce them; but the immediate question is the simpleone, has he infringed?Id .Infringement "is a strict liability offense, and a, ust award damages ,

adequate to compensate for the infringement, 35 U S C 284, regardless of the intent,culpability or motivation of the infringer." Jurgens v. CBK Ltd. , 80 F.3d 1566 , 1570 n.2(Fed. Cir. 1966) (citation omitted) (citing Hilton Davis, 62 F.3d 1512, 1527 (Fed. Cir.1995)).

Further, U.S. law mandates a reasonable royalty as the floor below whichdamages shall not fall. 35 U.S.C. 284. See Stickle v. Heublein Inc., 716 F.2d 1550 , 219USPQ 377, 385 (Fed. Cir. 1983). A reasonable royalty is the amount a person, desiring tomanufacture, use, or sell a patented article or practice a patented method would be willingto pay as a royalty.The royalty arrived at must be reasonable under all the circumstances; that is, it

must be at least a close approximation of what would be "adequate to compensate" forthe "use made of the invention by the infringer" as required by 284. Fromson v. WesternLitho Plate & Supp. Co., 853 F.2d 1568, 7 USPQ2d 1606 (Fed. Cir. 1988). It is ahypothetical royalty resulting from arms-length negotiations- between a licensor and alicensee.

A logical measure of a hypothetical reasonable royalty is an actual, establishedroyalty paid by others. And even if there is no existing royalty rate, it is appropriate toconsider royalties paid by others in the industry for use of a comparable patent. AmericanOriginal Corp. v. Jenkins Food Corp., 774 F.2d 459, 227 USPQ 299 (Fed. Cir. 1985).Here, Sorensen R&D has established a pre-litigation floor for a reasonable royalty rate by

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Rodney SchneidmillerDecember 13, 2012Page 9 of 9

licensing the 460 patent for a standard royalty rate of $240,000 or 6% of the total grosssales of the Accused Products for a release of the Accused Products.There is a narrow window of opportunity at this early stage wherein the parties

can resolve this matter without incurring high costs and legal fees through amicablediscussions leading to a license agreement. We look forward to receiving SterlingInternationals substantive response to our infringement assertions within thirty (30)days. Further, we are enclosing a binder illustrating a selection of products manufacturedby Sorensen R&Ds licensees.

Finally, Sorensen R&D is not subject to personal jurisdiction in any state exceptCahforma pursuant to the holding in Radio Systems Corporation v Ac cession, Inc, CaseNo. 2010-1390 (C.A. Fed., Apr. 25, 2011). Further, under the published opinion inNordica USA Corp v Jens Ole Sorensen, 475 F Supp 2d 128 (D N H 2007) and theunpublished opinions in Head USA, Inc. v. Jens Erik Sorensen, United States DistrictCourt of Connecticut, Case No. 3 :06-cv-00983 and Big Lots Stores, inc. v. SorensenResearch and Development Trust, United States District Court of Ohio, Case No. 2:08-cv-00506 the courts found that Sorensen R&D is not subject to personal jurisdiction inNew Hampshire, Connecticut, and Ohio For the same reasons articulated in theseopinions, Sterling International is on notice that there is no personal jurisdiction in anystate in the United States of America except California.

Your anticipated courtesy in working with us toward a rapid and amicableresolution of this matter is greatly appreciated.

Sincerely,

QcChris KuczynskiRegistered In-House C ounsel

End: Drawing No. D-7279Claim Chart for Drawing No. D-7279U.S. Patent No. 6,599,460Binder

EXHIBIT BPage 21



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U.S. PATENT NO. 6,599,460Sterling International, Inc.

Claim Chart for Rescue W-H-Y Insect TrapSorensen R&D Drawing No. D-7279

CLAIM I -- 460 PATENT REMARK REM. REFNO. FIGURE.

A method of injection-molding a product that The Accused Product shows a product I Figs 1includes at least one thin wall, comprising thesteps of: that includes at least one thin wail and 2comprising the steps of (a) combining(a) combining a plurality of mold parts to define

a mold cavity for forming the product and at a plurality ofmold parts to define aleast one gate from which fluid plastic material mold cavity for forming the productmay be injected into the mold cavity and at least one gate from which fluid

plastic material may be injected intothe mold cavity

wherein the mold cavity includes at least one At least one thin-wall cavity section is 2 Figsthin-wall cavity section and identified. and 2at least two opposed flow chambers that adjoin At least two opposed flow chambers 3 Figs Iopposite edges of the thin-wall cavity section that adjoin opposite edges of the thin- and 2for directing injected fluid plastic material fromexit positions of the said at least two opposed wall cavity section for directingflow chambers into corresponding entrance injected fluid plastic material from exitpositions of the at least one thin-wail cavitysection positions of the said at least two

opposed flow chambers intocorresponding entrance positions ofthe at least one thin-wall cavitysection are identified.

to thereby form at least one thin-wail portion of At least one thin-wall portion of the 4 Figs. 1,the product, product is identified. 2, and 3wherein the at least one thin-wail cavity section At least one thin-wall cavity section 5 Figs. 1,includes at least one zone that is located includes at least one zone that is 2 and 3between said at least two opposed flowchambers, and located between at least two opposed

flow chambers.

Claim Chart for Sorensen R&D Drawing No. D-7279EXHIBIT BPage 22



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CLAIM I -- 460 PATENT REMARK REM. REF.NO. FIGURE

wherein within the at least one zone inscribed- Within the at least one zone inscribed- 6 Figs. 2sphere dimensions at each entrance positionare smaller than inscribed-sphere dimensions sphere dimensions at each entrance and 3at the corresponding exit position of the position are smaller than inscribed,-adjoining flow chamber; and sphere dimensions at the

corresponding exit position of theadjoining flow chamber.

(b) injecting fluid plastic material from the gate Fluid plastic material is injected from 7into the mold cavity to form the product: the gate into the mold cavity to formthe product.

wherein step (a) comprises combining mold Step (a) comprises combining mold 8parts that define a said mold cavity In whichwithin said at least one zone of the at least one parts that define the mold cavity inthin-wall cavity section the thickness of the at which within the at least one zone ofleast one thin-wall cavity section increases inthe general direction of flow within the flow the at least one thin-wall cavitychambers adjoining said zone section the thickness of the at least

one thin-wall cavity section increasesin the general direction off/ow withinthe flow chambers adjoining said zone.

with said increase being at less than a it is substantially likely, within the 9threshold rate to thereby prevent injected fluidplastic material so directed into the at least one meaning of Title 35 U S C 295, thatzone from at any time surrounding any the in s at less than a thresholdgaseous void within the at least one zone. rate to thereby prevent injected fluid

plastic material so directed into the atleast one zone from at any timesurrounding any gaseous void withinthe at least one zone.

Claim Chart for Sorensen R&D Drawing No. D-7279EXHIBIT BPage 23



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ZONE r4

1 S E C T I O N A-A

FIG.2

AM

SORENSEN RESEARCH & DEVELOPMENTDRAWING NO. D-7279

RESCUE W-H-Y INSECT TRAPACCUSED

ZONELOWFLOWCHAMBERHAMBERPRODUCT m

FIG.3

11 4 -FIG.1

EXHIBIT BPage 24



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UNITED STATES DISTRICT COURTCENTRAL DISTRICT OF CALIFORNIA

NOTICE OF ASSIGNMENT TO UNITED STATES MAGISTRATE JUDGE FOR DISCOVERY

This case has been assigned to District Judge Audrey B . Collins and the assigneddiscovery Magistrate Judge is Robert N. Block.The case number on all documen ts fi 1 ed with the Court should read as follows:

CV13938 ABC (RNBx)Pursuant to General O rder 05-07 of the U nited States District Court for the CentralDistrict of California, the M agistrate Judge h as been designated to h ear discovery related

motions.

All discovery related motions should be no ticed on the calendar of the Mag istrate Judge

NOTICE TO COUNSELA copy of this notice must be served with the summons and complaint on all defendants (if a removal action isfiled, a copy of this notice must be served on all plaintiffs).Susequent documents must be filed at the following location:

[ 4 Western Divisionj Southern Divisionj Eastern Division312 N. Spring St., Rm. G-811 West Fourth St., Rm. 1-053470 Twelfth St., Rm. 134Los Angeles, CA 90012anta Ana, CA 92701-4516iverside, CA 92501Failure to file at the proper location will result in your documents being returned to you.CV-18 (03/06)OTICE OF ASSIGNMENT TO UNITED STATES MAGISTRATE JUDGE FOR DISCOVERY



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Name & A ddress:Scott C. Moore (CA SBN 203 18 1)MORRISON & FOERSTER LLP55 5 W est Fifth St.Los Angeles, CA 90013-1024

UNITED STATES DISTRICT COURTCENTRAL DISTRICT OF CALIFORNIA

Sterling International, Inc.,ASE NUMBERPLAINTIFFV 13-0093B,_ adr(V .Sorensen Research and D evelopment Trust,SUMMONS

DEFENDANT(S).

TO: DEFENDANT(S):A lawsuit has been filed against you.Within 21 days after service of this summons on you (not counting the day you received it), youmust serve on the plaintiff an answer to the attached W com plaint 0 mended complaint

O counterclaim 0 cross-claim or a motion under Rule 12 of the Federal Rules of Civil Procedure. The answeror mo tion must be served on the plaintiffs attorney, Sco tt C. Mo orewhose address isM orrison & Foerster LLP, 55 5 W est Fifth St. , Los Angeles, CA 90 013-1024 If you fail to do so ,judgment by default will be entered against you for the relief demanded in the com plaint. You also m ust f ileyour answer or m otion with the court.FEB -8 2013Dated: Clerk, U.S. District CourtBy:A R I L Y N M f ~Deputy Cler /(Seal of the Court)[Use 60 days if he defendant is the United States or a United States agency, or is an officer or em ployee of the United States. Allowed60 days by Rule 1 2(a)(3)].

CV-01A(10/11UMMONSCase 3:13-cv-01415 Document 1 Filed 02/08/13 Page 30 of 32


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UNITED STATES DISTRICT COURT, CENTRAL DISTRICT OF CALIFORNIACIVIL COVER SHEET

1(a) PLAINTIFFS (Check box if you are representing yourself 0)EFENDANTSSterling International, Inc.orensen Research and Develo ment Trust0(b) Attorneys (Firm Name, Address and Telephone Number. If you are representingttorneys (If Known)yourself, provide same.)Scott C. Moore, Morrison & Foerster LLP, 555 W.5th St., L.A., CA 90013,213.892.5200

Brian F. McMahon, John D Denkenberger, James W. Anable, Christensen OConnorJohnson Kindness PLLC, 1420 5th Ave, Seattle, WA 9810, 206.682.8100

IL BASIS OF JURISDICTION (Place an X in one box only.)II. CITIZENSHIP OF PRINCIPAL PARTIES - For Diversity Cases Only(Place an X in one box for plaintiff and one for defendant.)0 1 U.S. Government Plaintiff6 Federal Question (U.S.TF DEFTF DEFGovernment Not a Party)itizen of This State1 01ncorporated or Principal Place 04 04of Business in this State0 2 U.S. Government Defendant 04 Diversity (Indicate Citizenship Citizen of Another State2 02 Incorporated and Principal Place 0 5 0 5of Parties in Item III)f Business in Another State

Citizen or Subject of a Foreign Country 03 03 Foreign Nation606IV . ORIGIN (Place an X in one box only.)li Original2 Removed from 0 3 Remanded from 04 Reinstated or 0 5 Transferred from another district (specify): 0 6 Multi-7 Appeal to DistricProceedingtate Courtppellate Courteopenedistrictudge fromLitigationagistrate JudgeV. REQUESTED IN COMPLAINT: JURY DEMAND: 0 Yes IlGti (Check Yes only if demanded in complaint.)CLASS ACTION under F.R.C.P. 23: 0 Yes 0 NoMONEY DEMANDED IN COMPLAINT: $______________________VI . CAUSE OF ACTION (Cite the U.S. Civil Statute under which you are filing and write a brief statement of cause. Do not cite jurisdictional statutes unless diversity.)35 U.S.C. 1 et seq., Invalidity and non-infringement of U.S Patent No. 6,599,460VII. NATURE OF SUIT (Place an X in one box only.)omsmwms- j . IOTs *IN

0400 State Reapportionment 0 110 Insurance PNAL INJURY PERSONAL 1flT 0 - Cl 710 Fair Labor Standards0410 Antitrust 0 120 Marine 0310 Airplane ":ROPERTY 0 510 Motions to Act0430 Banks and Banking 0 130 Miller Act 0315 Airplane Product 0370 Other Fraud Vacate Sentence 0720 LaborfMgmt.0 450 Commerce/ICC 0 140 Negotiable Instrument Liability 0371ruth in Lending Habeas Corpus RelationsRates/etc. 0 150 Recovery of 0320 Assault, Libel & 0 380 Other Personal 0 530 General 0 730 Labori?vlgmt.0460 Deportation overpayment & Slander Property Damage 0 535 Death Penalty Reporting &0 470 Racketeer Influenced Enforcement of 0 330 Fed. Employers 0 385 Property Damage 0 540 Mandamus/ Disclosure Actand Corrupt Judgment Liability Product Liability Other 0740 Railway Labor ActOrganizations 0 151edicare Act 0340 Marine BANKRtJPTY 0 550 Civil Rights 0 790 Other Labor0480 Consumer Credit 0 152 Recovery of Defaulted 0 345 Marine Product 0422 Appeal 28 USC 0 555 Prison Condition Litigation0490 Cable/Sat TV Student Loan (ExcI. Liability0350I 15 8 FQBEFTUREj 0791mpI. Ret Inc.0 810 Selective Service Veterans) 0355 Motor Vehicle 0423 Withdrawal 28 P?T Security Act0850 Securities/Commodities/ 0 153 Recovery of Product Liability .USC157 0 610 Agriculture PJOPEkT\IIGI3TSExchange Overpayment ofVeterans Benefits 0360 Other Personal CIVIL RIGHTS1 0 620 Other Food & 0,820 Copyrights0 875 Customer Challenge 12 Injury 0 441 Voting Drug 830 PatentUSC 3410 0 160 Stockholders Suits 0362ersonal Injury- 0442 Employment 0 625 Drug Related 0 840 Trademark0 890 Other Statutory Actions 0 190 Other Contract Med Malpractice 0 443 Housing/Acco- Seizure of SOCIAL SECURITY0891gricultural Act 0 19 5 Contract Product o 36 5ersonal Injury- mmodations Property 21 USC 0 861IA (I 395fl)0 892 Economic Stabilization Liability Product Liability 0 444 Welfare 88 1 0 862 Black Lung (923)Ac t 0 196 Franchise 0368 Asbestos Personal 0 445 American with 0 630 Liquor Laws 0 863 DIWC/DIWW0 893 Environmental Matters REALPROPERTY Injury Product. Disabilities 0 640 R R & Truck (405(g))0 894 Energy Allocation Act 0 210 Land Condemnation.iability Employment 0 650 Airline Regs 0 864 SSID Title XVI0 895 Freedom of Info Act 0 220 Foreclosure IMMIGRATION 0 446 American with 0 660 Occupational 0 865 RSI (405(g))0 900 Appeal of Fee Determi 0 230 Rent Lease & Ejectment 0462aturalization Disabilities Safety /Health FEDERAL TAX SUITSnation Under Equal 0 240 Torts to Land Application Other 0 690 Other 0 870 Taxes (U.S. PlaintiffAccess to Justice 0 245 Tort Product Liability 0463 Habeas Corpus- 0 440 Other Civil or Defendant)0 950 Constitutionality of 0 290 All Other Real Property Alien Detainee Rights 0 871RS-Third Party 26State Statutes 0465ther Immigration USC 7609ActionsFOR OFFICE USE ONLY: Case Number:illy 1 .7V 1 d

AFTER COMPLETING THE FRONT SIDE OF FORM CV-71, COMPLETE THE INFORMATION REQUESTED BELOW.CV-71 (05/08)IVIL COVER SHEETage 1 of



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UNITED STATES DISTRICT COURT, CENTRAL DISTRICT O F CALIFORNIACIVIL COVER SHEET

VHI(a). IDENTICAL CASES: Has this action been previously filed in this court and dismissed, remanded or closed? l "No DYesIf yes, list case number(s):VIll(b). RELATED CASES: Have any cases been previously fi led in this court that are related to the present case? []No I "YesIf yes, list case number(s): 2:1 1-cv-03720-GWCivil cases are deemed related if a previously filed case and the present case:(Check all boxes that apply) 0 A. Arise from the same or closely related transactions, happenings, or events; or

"B. Call for determination of the same or substantially related or similar questions of law and fact; or0 C. For other reasons would entail substantial duplication of labor if heard by different judges; orlID. Involve the same patent, trademark or copyright, and one of the factors identified above in a, b or c also is present.

IX. VENUE: (When completing the following information, use an additional sheet if necessary.)(a) List the County in this District; California County outside of this District; State if other than California; or Foreign Country, in which EACH named olaintiff residesIll Check here if the government, its agencies or employees is a named plaintiff. If this box is checked, go to item (b).

County in this D istrict:*alifornia County outside of this District; State, if other than California; or Foreign CountrySterling International, Inc., Washington State

(b) List the County in this District; California County outside of this District; State if other than California; or Foreign Country, in which EACH named defendant residesI Check here if the government, its agencies or employees is a named defendant. If this box is checked, go to item (c).County in this D istrict:*alifornia County outside of this District; State, if other than California; or Foreign CountrySorensen Research and Development Trust, San Diego County, Calilornia(c ) List the County in this District; California County outside of this District; State if other than California; or Foreign Country, in which EACH claim arose.ioIe; In rand cunuemnanon cases, use me location of the tract oi lanu Involved.County in this District:*alifornia County outside of this District; State, if other than California; or Foreign Country

Washington State

* Los Angeles, Orange, San Bernardino, Riverside, Ventura, Santa Barbara, or San Luis Obispo Counties

X. SIGNATURE OF ATTORNEY (OR PRO PER):ate 1/7 12-e t- 3Notice to Counsel/Parties: The CV-71 (JS-44) Civil Cover Sheet and the information contained herein neither replace nor supplement the filing and service of pleadingsor other papers as required bylaw. This form, approved by the Judicial Conference of the United Stites itSeptember 1974, is required pursuant to Local Rule 3-I is not filedbut is used by the C lerk of the Co urt for the purpose of statistics, venue and initiating the civil do cket sheet. (For mo re detailed instructions, see separate instructions Sh eet.)Key to Statistical codes relating to Social Security Cases:Nature of Suit Codebbreviation Substantive Statement of Cause of Action86 1IA All claims for health insurance benefits (Medicare) under Title 18, Part A, of the Social Security Act, as amended.Also, include claim s by ho spitals, skilled nursing facilities, etc., for certification as provid ers of services unde r sheprogram. (42 U.S.C. 1935FF(b))8 62L All claims for "Black Lung" benefits under Title 4, Part B, of the Federal Coal M ine Health and Safety Act of 1 969.

(30 U.S.C. 923)8 63IW C All claims filed by insured workers for disability insurance benefits under Title 2 of the Social Security Act, asamended; plus all claims filed for childs insurance benefits based on disability. (42 U.S.C. 405(g))86 3IW W All claims filed for widows or widowers insurance benefits based on disability under Title 2 of the Social SecurityAct, as amended. (42 U.S.C. 405(g))8 6 4SI D All claims for supplemental security income payments based upon disability filed under Title 16 of the Social SecurityAct, as amended.86 5SI All claims for retirement (old age) and survivors benefits tinder Title 2 of the Social Security Act, as amended. (42U.S.C. (g))


Sterling International v. Sorensen Research and Development Trust

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Transcript of Sterling International v. Sorensen Research and Development Trust